However, it is only since 2014 that HMRC has been able to issue Advanced Payment Notices to expatriates who have used disputed tax avoidance / tax minimisation schemes. These APNs mean that those under investigation must pay upfront and dispute later.
There are a number of issues to consider for expatriates under investigation, not least for high net worth individuals living abroad who may find themselves unfairly targeted as a result of political motives and internal HMRC investigation targets.
Whatever the case, and whatever the possible rights and wrongs, it is essential that expats respond promptly to local tax authorities operating on behalf of HMRC – and the first component of this should be ensuring reliable expat financial advice together with jurisdictional legal advice.
Once this has been done there may, depending on the individual case, be plenty of scope for challenging the recovery of the claimed liability using MARD procedures.
There has been unity among groups representing British expats living in EU nations – particularly Spain, Germany France, Belgium, and Italy – in an attempt to convince MPs to ensure expats have their rights sufficiently protected during Brexit.
Malta’s favourable residency schemes are likely to stay in place for some time after Brexit and this has propelled the Mediterranean archipelago to the top of the list for some UK citizens who are considering their options for relocation in the near future.